All appeals dismissed; finding of anti-competitive bid-rigging upheld under Sections 3(3)(c), 3(3)(d) read with 3(1); cease-and-desist and total-turno...
Central Government notifies 11.541-hectare Special Economic Zone for semiconductor manufacturing; Approval Committee constituted, ICD status effective...
Government appoints National Customs Targeting Centre-Passenger director as customs officer with powers under PNR Regulations, 2022 and Sections 30A, ...
ITAT upholds the assessment under s.143(3) read with s.144C(13), finding the reference under s.92CA(1) valid and the TPO acted within jurisdiction; the assessment order is not void and Grounds 1-3 are dismissed. The Project Office is characterized as merely an executing arm of the Head Office; transfer pricing adjustments for onshore services are sustained as the taxpayer failed to demonstrate arm's-length remuneration. For offshore supplies, the Tribunal concludes the Project Office's post-supply obligations created a taxable nexus in India, justifying attribution under s.9 and Article 7 of the India-China DTAA. The CUP method is rejected as the MAM due to lack of strict comparability; the impugned TP adjustments are consequently upheld.
ITAT upholds the assessment under s.143(3) read with s.144C(13), finding the reference under s.92CA(1) valid and the TPO acted within jurisdiction; the assessment order is not void and Grounds 1-3 are dismissed. The Project Office is characterized as merely an executing arm of the Head Office; transfer pricing adjustments for onshore services are sustained as the taxpayer failed to demonstrate arm's-length remuneration. For offshore supplies, the Tribunal concludes the Project Office's post-supply obligations created a taxable nexus in India, justifying attribution under s.9 and Article 7 of the India-China DTAA. The CUP method is rejected as the MAM due to lack of strict comparability; the impugned TP adjustments are consequently upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
